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Privacy Policy

This is the Privacy Policy of ANONYMOUS S.A.R.L.
This document was last updated on May 21th, 2018.

1- Introduction

This Privacy Policy describes how ANONYMOUS S.A.R.L. (“SmartVPN”, “we”, “us” or “our”) as a data controller collects and use your personal data (“Information”), for example when you contact us, apply for a job, visit or use one of our websites, mobile applications, portals, or other parts of our network (each a “Site”), or use our products and services (each a “Service”). This Privacy Policy also explains the rights available to you in respect of your personal data.
By using a Site and/or a Service, and providing us with your personal data, you consent to the processing of your personal data in the manner set out in this Privacy Policy.

2- What information do we collect, how and why ?

2-1. Data that you provide voluntarily to us

When you use our Site or Service, or you otherwise communicate with us, we may ask you to provide certain personal data voluntarily, including but not limited to :

We may ask you to provide some or all of this personal data when you register an account with us, subscribe to our marketing communications, purchase products or services, and/or submit enquiries to us. We use this information to create and administer your account, send you marketing communications, provide you with the products and services you request, and to respond to your enquiries.

2-2. Data collected automatically

When you use our Site, products, or services, we may collect certain data automatically from your computers or devices (including mobile devices). The data we collect automatically may include your IP address (explained further below), device type, operating system details, unique device identification numbers (including mobile advertising identifiers), browser-type, browser language, geographic location (as explained further under “Location information”) and other technical information. Collecting this data enables us to better understand the visitors who use our Site, products, and services, including where they come from and what features are of interest to them. We use this information for our internal analytics purposes, and to improve the quality, relevance, and security of our Site, products and services.

For example, every time you connect to the Site, we store a log of your visit that contains the data described above. We can then customize your user experience by displaying Services relevant to you, in the appropriate language and currency. We may also use this information to block IP addresses where there is a breach of the terms and conditions for use of the Site.

Some of the data may be collected automatically using tracking technologies, as explained further under “Cookies and similar tracking technology”.

2-3. Cookies and similar tracking technology

A cookie is a piece of text that gets entered into the memory of your browser by a website, allowing the website to store information on your machine and later retrieve it. Our Site, products, and services may use cookies and other tracking technologies (collectively, "Cookies") to distinguish you from other users and better serve you when you return to the Site, product, or service, and to monitor and analyse the usage of the Site, product, or service.
Cookies also enable us and our third party partners to track and target the interests of our users to enhance the onsite or in-product experience through content and features.
We, along with our service providers, may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Site, product, or service, as well as serve you ads and personalize/customize your experience when you are using our Site, product, or service and/or when you are on other websites where those cookies can be accessed. We may also include Web beacons in email messages, newsletters, and other electronic communications to determine whether the message has been opened and for other analytics and personalization. Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser's toolbar. If you choose to decline cookies, please note that your ability to sign in, customize, or use some of the interactive features of our Site or Service may be impeded, and the content you see may not be as relevant to you.

The types of cookies and similar technologies that we use are detailed below:

Noms de domaine
Domain Registrant Agreement [EN]
Termes et conditions DOTMA
Category Purpose

Session Information

We use temporary cookies which are erased when you close your web browser. When you restart your browser and revisit the Site, the Site will not recognize you. These cookies are essential to navigate parts of the Site, register or order new Services.

Geographic Information

We use cookies to allow us to detect a user’s geographical location, mainly using the IP address of the connection point. In some cases, this cookie can redirect the user to a website in the country where they appear to be connected and display prices in the corresponding currency.


These cookies collect information on how visitors use our website, such as the number of visitors and pages visited. We collate and retain information for reporting and monitoring purposes, in order to improve our website.

Pixel Tags

We use pixel tags from the following third parties, to help us improve use of the Site and our services, and know when content has been shown to you:

Content Delivery Networks

These cookies are used to store geographical informations about the user to serve him content from servers located in the closest datacenters to him and improve the display speed of our content. These cookies are from CloudFlare. For additional information regarding CloudFlare’s data privacy and cookies, please go to CloudFlare’s Privacy policy

2-4. Location information

We may collect different types of information about your location, including general information (for example IP address or ZIP code) and more specific information (for example GPS-based functionality on mobile devices when used to access a Site, product, or service). This information may be used to customize the services provided to you, such as location-based information and features. In order to do this, your location information may be shared with our agents or vendors. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details.

3- Legal basis for processing personal data

Our legal basis for collecting and using personal data will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you only where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so.
In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
If we collect and use your personal data in reliance on our legitimate interests (or those of any third party) other than as described in this privacy policy, we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “Contact” Section.

4- Sharing and disclosure of your personal data

We may transfer or disclose your personal data to the following categories of recipients:

Whenever we share personal data, we take all reasonable steps to ensure that it is treated securely and in accordance with this privacy policy.

5- Data retention

We retain personal data we collect from you for as long as necessary for the purposes for which the personal data was collected or where we have an ongoing legitimate business need to do so (for example, to provide you with a product or service you have requested, to ensure that transactions can be processed, settled, refunded, charged back, or to identify fraud), or to comply with applicable legal, tax, or regulatory requirements. Even if you close your account, we will retain certain information in order to meet our obligations. When we have no ongoing legitimate business need to process your personal data, we will either securely destroy, erase, delete or anonymise it, or if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

6- Use by children

Usage by children of the Site or the Service are not intended for persons under the age of 16. By using the Site or Service, you hereby represent that you are at least 16 years old. If you have reason to believe that a child under the age of 16 has provided Personal Data to ANONYMOUS S.A.R.L. through this Site, please contact us using the contact details provided under the “Contact” Section and we will endeavor to delete that information from our databases.

7- Your data protection rights

You have the following data protection rights:

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

8- Data security

While we strive to protect your personal data, no data transmission or storage can be guaranteed as 100% secure. We endeavour to protect all personal data using reasonable and appropriate physical, administrative, technical, and organisational measures, and in accordance with our internal security procedures and applicable law. These safeguards vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology.
If you have been given or have created log-in details to provide you with access to certain parts of our Site (for example our partner portal), you are responsible for keeping those details confidential in order to prevent unauthorised access to your accounts.

9- Contact

We have appointed a person who is responsible for the protection and security of your personal data. If you have any questions, comments, concerns, grievances, or complaints about this privacy policy or the manner in which we treat your personal data, or if you want to request any information about your personal data or believe that we are holding incorrect personal data on you, please contact our Data Protection Officer at

10- Changes to our privacy policy

We reserve the right to amend or vary this policy from time to time to reflect evolving legal, regulatory, or business practices. Please check this page periodically for changes. We will obtain your consent to any material privacy policy changes if and where this is required by applicable data protection laws. You can see when this privacy policy was last updated by checking the “last updated” date displayed at the top of this page.
By continuing to use the Site and/or the Service or providing us with information following such a replacement Policy being updated, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.